Citizens for North County
What level of toxaphene exposure would you say is acceptable for you, your friends and family, for the hiking and biking trails, picnic areas and other passive recreational activities promised in Measure A?
The City of Carlsbad’s own 3rd party peer reviewer has revealed that the Measure A environmental assessment fails to call for detailed sampling and analysis of those parts of post-agricultural land slated for hiking and biking trails, picnic areas and other passive recreational activities that contain elevated levels of toxaphene.
(As of this writing, this failure to call for detailed sampling and analysis did not make it into the City of Carlsbad Summary of Key Issues for Measure A Environmental Analysis of Soils.)
The Measure A environmental assessment employs a much less stringent standard to evaluate toxaphene levels in the soil that does not factor-in direct exposure to children.
It provides no conceptual models to show where hiking and biking trails, picnic areas and other passive recreational activities may be overlaying post-agricultural lands with elevated levels of toxaphene, fails to address this issue, and fails to discuss the potential release of hazardous materials in the area, as well as potential soil remediation efforts.
The 3rd party peer reviewer has also noted that no Environmental Protection Features require soil testing for contamination.
The 2004 Lennar Communities environmental assessment for residential land use on the same site concluded that 21 out of 25 samples contained unacceptable levels of toxaphene. It estimated that 191,000 cubic yards of contaminated soil would need to be removed/ remediated for the project. (Depending on soil densities, this could be as much as 58 full-size Olympic swimming pools, assuming a nominal pool depth of 2m.) The estimated cost at that time for soil removal/ remediation was $16.4 million.
The Measure A environmental assessment concludes that with the current and anticipated future Measure A zoning, the soil is suitable for open space and agricultural land uses.
In the worse case scenario, the Measure A environmental assessment estimates less than 6,000 cubic yards of soil unacceptable for use. (This soil is located in the Measure A agriculture zone, and levels would only become unacceptable if zoning there were changed in the future to commercial/industrial use, according to the assessment. In this soil toxaphene levels are so high they exceed even the much less stringent standards for commercial/industrial land use.)
You can see (below) both the Measure A and the Lennar Communities environmental assessments’ aerial toxaphene concentration maps of the same site, with the various sampling locations and corresponding elevated toxaphene levels. You can also see below the third party peer reviewer report and other citations.
What other shortcuts might there be in the Measure A, shortcuts that could impact our health, and that of our children and grandchildren?
So what level of toxaphene exposure would you say is acceptable for you, your friends and family, for the hiking and biking trails, picnic areas and other passive recreational activities slated for in Measure A?
Without CEQA law and the CEQA process, you may not have much of a say at all.
And this is just part of the reason why we oppose Measure A.
The special election for Measure A is on Feb 23. Every vote counts. Please vote.